White Corporation has manufactured lawn furniture for years. in addition, for the last 3 years, white has operated a separate division that sells barbecue equipment. Helen, an individual, and Gray Corporation each acquired 100 shares of stock in White ( basis of $100,000 per share) 10 years ago. IN the current year, the bbq equipment division is entirely destroyed by fire. White Corp decides to discontinue the business and distributes all of the $4 million of insurance proceeds collected as a result of the fire to helen and Gray Corp in redemption of 20 shares of stock from each shareholder. White Corp has E&P of $7 million. What are the tax consequences for three parties; White Corp, Gray Corp and Helen?